REVISION OF SOLAS CHAPTERS III AND IV FOR MODERNIZATION … · GMDSS Definition 7 Introduction of a...

H:\IMO-ITU EG\IMO-ITU EG 2017\documents\IMO-ITU EG 13-5-2.docx

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JOINT IMO/ITU EXPERTS GROUP ON MARITIME RADIOCOMMUNICATION MATTERS 13th meeting Agenda item 5

IMO/ITU EG 13/5/2

30 June 2017

ENGLISH ONLY

REVISION OF SOLAS CHAPTERS III AND IV FOR MODERNIZATION OF THE GLOBAL MARITIME DISTRESS AND SAFETY SYSTEM (GMDSS), INCLUDING RELATED AND

CONSEQUENTIAL AMENDMENTS TO OTHER EXISTING INSTRUMENTS

Comments and proposals for the draft revised SOLAS chapter IV

Submitted by Denmark

SUMMARY

Executive summary: This document contains comments and proposals for the draft

revisions of SOLAS chapter IV given in document

IMO/ITU EG 13/5, annex 1

Action to be taken: Paragraph 31

Related documents: IMO/ITU EG 13/5

INTRODUCTION 1 This document contains comments and proposals for the draft revised SOLAS chapter IV as given in document IMO/ITU EG 13/5, annex 1. 2 The comments are in paragraphs 4 to 26 and proposals are provided in paragraphs 27 to 30. 3 At annex, the draft revised SOLAS chapter IV as given in IMO/ITU EG 13/5, annex 1 is included with numbered references to the comments in the main body of this document - i.e. no changes or comments are inserted in the text of the annex. The numbered references are indicated with bright green highlight (e.g. #1). COMMENTS Editorial changes 4 In general we would propose that editorial changes are kept at a minimum, in order to keep focus on the many substantial changes that will be made to SOLAS chapter IV. We are of

IMO-ITU EG 13/5/2


the view that editorial changes should be made where they will provide clearer and more readable text, where alignment of text within SOLAS chapter IV is achieved and errors are corrected. 5 In relation to the proposals in SOLAS regulations IV/1.1, IV/3.1.2, IV/3.2.1 and IV/3.2.2 (#1), these are not required for the purposes mentioned above and could be omitted.

6 The proposals in SOLAS regulation IV/2.1.14 (delete "communication"), SOLAS regulation IV/2.1.16 (align singular / plural), SOLAS regulation IV/4.1.2 (delete hyphen), SOLAS regulation IV/6.2.5 (Make use of "GMDSS identities" definition.), SOLAS regulation IV/7.1.7 (delete hyphen), SOLAS regulation IV/9.1.3.3 (delete superfluous "by" and add hyphen), SOLAS regulation IV/10.1.1.3 (add "relays"), SOLAS regulation IV/12.1.4 (keep "alert", add hyphen) (#2) could be introduced in accordance with the purposes mentioned above. GMDSS Definition 7 Introduction of a definition of Global Maritime Distress and Safety System (GMDSS) in new SOLAS regulation IV/2.1.6 is not supported. We do not agree that there is a need to clarify types of functional requirements in SOLAS regulation IV/4 through a definition of GMDSS. The functional requirements are fully defined in SOLAS regulation IV/4, and a simplified definition would introduce a risk of ambiguity and inconsistency.

8 The definition in new SOLAS regulation IV/2.1.6 and comments in SOLAS regulations IV/4.1.1 and IV/4-1 (#3) are not supported. Alignment with ITU-R Radio Regulations 9 Generally the language and terms used in SOLAS chapter IV should be aligned with ITU-R Radio Regulations (RR). Especially where direct dependency on the RR exists or reference to the RR is made, it is essential that use of different terms is avoided. As an example a "DSC distress alert" is well defined in the RR and different terms should not be used. 10 At the same time, we are of the view that terminology and general language should not unconditionally be aligned with the RR. In some cases, a strictly and formally correct use of terms defined in RR, would result in language that is less readable. As an example, the change proposed in SOLAS regulation IV/2.1.1 (inserted below) would divert from commonly used language and makes it more difficult to read. We would therefore not support the changes shown.

".1 Bridge-to-bridge radiocommunications means safety telecommunications between ships from the position from which the ships are normally navigated, conducted by radio."

11 In our opinion, the existing text is generally well understood and has not been the cause of misunderstandings. 12 Further, SOLAS chapter IV is under the heading "Radiocommunications", and it would therefore in our view not be necessary to replace all occurrences of "communication" with "radiocommunication".

IMO-ITU EG 13/5/2


13 It is also noted that WRC-19 includes an agenda item to consider possible regulatory actions to support GMDSS Modernization, and amendments to the RR could be proposed if found necessary. 14 On this background we do not support the changes proposed in SOLAS regulations IV/2.1.1, IV/2.1.5, IV/2.1.11ter, IV/2.1.15bis, IV/4.1.1.8, IV/4.1.2, IV/4.1.3, IV/7.1.7, IV/7.1.8, IV/8.2, IV/9.3, IV/12.3.2, IV/15.8 (#4) Functional requirements 15 Denmark continues to support the functional requirements as decided in the High Level Review of the GMDSS, approved by NCSR 1 and noted by MSC 94. The draft revised SOLAS chapter IV given in NCSR 3/17, annex 1 reflects the functional requirements as decided in the High Level Review. 16 In the discussions it was considered and decided that security related communication should be included in SOLAS chapter IV, even though it is not a GMDSS functional requirement and the detailed requirements would be elsewhere. One objective is all radio communication requirements would be in SOLAS chapter IV. It has also been noted that security related communication may be performed by GMDSS equipment. 17 During the development of the functional requirements, it has been decided that the term "public correspondence traffic" should not be included. The term is closely related to commercial communication via coast radio stations on VHF, HF and MF. Availability of these services is decreasing rapidly and this type of communication is handled via other commercial services. The definition of "Other communications" in NCSR 3/17, annex 1 includes public correspondence traffic. We do not believe that reintroduction of the term public correspondence is necessary for clarity or otherwise. 18 An element that has been considered during the development of the High Level Review is the possibility to use goal based requirements. It was concluded that the core functionality of the GMDSS require stringent requirements in order to ensure the necessary level of compatibility and reliability, but in the case of Other communication a more goal based approach is possible. 19 The SOLAS regulations IV/4.1.1.7 Transmitting and receiving safety related information and IV/4.1.1.7bis Receiving Maritime Safety Information (MSI) were separated in order to make a distinction between the communication between stations and MSI which is shore-based broadcast only. Although transmitting and receiving safety related information is included in General communications, it is necessary for clarity to retain this subset of General communication as a separate functional requirement. 20 For this reason Denmark cannot support the proposed changed in SOLAS regulations IV/2.1.11ter, IV/2.1.15, IV/4.1.1.7 (deleted version and merged version), IV/4.1.2 (deleted version), IV/4.1.3 (deleted version), IV/7.1.8 (deleted version) (#5)

IMO-ITU EG 13/5/2


EPIRB remote activation 21 In our view the option for using remote activation of the EPIRB should be removed. Remote activation of EPIRBs was mainly a feature of the Inmarsat-E system but is not widely available with 406 MHz EPIRBs. Currently there are no obvious technical or economic reasons to justify development of remote activation functionality. 22 Keeping the option for remote activation in SOLAS chapter IV will result in maintaining unnecessary complexity of the regulations. 23 We therefore continue to support the text given in NCSR 3/17 and would not support re-introduction of the option as proposed in SOLAS regulations IV/6.4, IV/8.1.2, IV/9.1.3.1, IV/10.1.4.1 and IV/11.1.3.1 (#6) Exemption for ships constructed before 1997 24 We continue to support deletion of the regulations concerning exemption from carrying VHF DSC equipment for ships constructed before 1997, as given in NCSR 3/17. 25 We have indication from an equipment supplier, that the average cycle of replacement of radio equipment for convention ships is approximately 10 years. This information has not been analysed in detail and should be considered as an indicative example. However, considering further that the entry into force of these revisions will be 2024 - almost 30 years after the date contained in the exemption regulations, we believe that the actual number of ships concerned will be low. 26 Unless information is brought forward which indicate that a significant number of ships are affected by the regulations we would not support re-introduction of the SOLAS regulations IV/9.4, IV/10.4, IV/11.4 (#7) PROPOSALS SOLAS regulation IV/2/1/2 (definition of continuous watch) 27 Regulation 12 provides requirements for both radio and listening watches. In order to be consistent with Regulation 12, we propose to amend the definition of "Continuous watch" to also include listening watch. 28 It is proposed to amend SOLAS regulation IV/2.1.2 as follows:

".2 Continuous watch means that the radio and listening watch concerned shall not be interrupted other than for brief intervals when the ship's receiving capability is impaired or blocked by its own communications or when the facilities are under periodical maintenance or checks."

Consider relating shore-based maintenance of EPIRB to battery expiration. 29 In previous sessions of the Experts Group, it has been proposed to consider relating shore-based maintenance of EPIRB to battery expiration - which in some cases is longer than five years.

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30 To our knowledge, no conclusion on this proposal has been made, and we would therefore invite the Experts Group to consider whether an amendment to SOLAS regulation IV/15.9.2 found below would be appropriate:

".2 subject to maintenance at intervals not exceeding [five years] [the manufacturer’s battery expiration date], to be performed at an approved shore-based maintenance facility."

ACTION REQUESTED OF THE EXPERTS GROUP 31 The Joint IMO/ITU Experts Group is invited to:

.1 consider the comments provided in paragraphs 4 to 26 above; .2 consider the proposals in paragraphs 27 to 30 above; and .3 take action, as appropriate.

***

IMO-ITU EG 13/5/2 Annex 1, page 1


ANNEX

IMO-ITU EG 13/5, ANNEX 1

REVIEW AND MODERNIZATION OF THE GMDSS

PRELIMINARY DRAFT OF REVISED SOLAS CHAPTER IV (INCLUDING PART OF CHAPTER III)

_________________________________________________________________________________

SOLAS

CHAPTER III

Life-saving Appliances and Arrangements

TEXT revisions from Appendix 3, NCSR 3/17, Annex Comment

PART B

Requirements For Ships and Life-Saving Appliances

Section I – Passenger Ships and Cargo Ships

Regulation 6

Communications

1 Paragraph 2 applies to all passenger ships and to all cargo ships of 300 tons gross

tonnage and upwards.

2 Radio life-saving appliances

2.1 Two-way VHF radiotelephone apparatus

SOLAS requirements for Two Way VHF

radiotelephone apparatus and search

and rescue locating devices (originally

Search and Rescue Transponders

(SART)) were part of the 1983 SOLAS

Amendments and placed in chapter III,

which came into force in 1986 in




advance of the GMDSS. Because these

requirements form part of the GMDSS

as they address some of the functional

requirements they would be more

naturally located in chapter IV.

2.1.1 At least three two-way VHF radiotelephone apparatus shall be provided on every

passenger ship and on every cargo ship of 500 gross tonnage and upwards. At least two

two-way VHF radio-telephone apparatus shall be provided on every cargo ship of 300 tons

gross tonnage and upwards but less than 500 gross tonnage. Such apparatus shall

conform to performance standards not inferior to those adopted by the Organization. If a

fixed two-way VHF radiotelephone apparatus is fitted in a survival craft it shall conform to

performance standards not inferior to those adopted by Organization.

Moved to regulation IV/7.1.9

2.1.2 Two-way VHF radiotelephone apparatus provided on board ships prior to

1 February 1992 and not complying fully with the performance standards adopted by the

Organization may be accepted by the Administration until 1 February 1999 provided the

Administration is satisfied that they are compatible with approved two-way VHF

radiotelephone apparatus.

Obsolete provision

.2 Search and rescue locating devices

At least one search and rescue locating device shall be carried on each side of every

passenger ship and of every cargo ship of 500 tons gross tonnage and upwards. At least

one search and rescue locating device shall be carried on every cargo ship of 300 tons

gross tonnage and upwards but less than 500 tons gross tonnage. Such search and

rescue locating devices shall conform to performance standards not inferior to those

adopted by the Organization. The search and rescue locating devices shall be stowed in

such locations that they can be rapidly placed in any survival craft other than the liferaft or

liferafts required by regulation 31.1.4. Alternatively one search and rescue locating device

shall be stowed in each survival craft other than those required by regulation 31.1.4. On

ships carrying at least two search and rescue locating devices and equipped with free-fall

lifeboats one of the search and rescue locating devices shall be stowed in a free-fall

Moved to regulation IV/7.1.10




lifeboat and the other located in the immediate vicinity of the navigating bridge so that it

can be utilized on board and ready for transfer to any of the other survival craft.

* * * * *

SOLAS

CHAPTER IV

Radiocommunications

TEXT revisions from Appendix 3, NCSR 3/17, Annex

Comment Text affected by 2018 SOLAS amendments

Revisions proposed by members of Correspondence Group

PART A General Regulation 1

Application

1 Unless expressly provided otherwise, this chapter applies to all ships as provided in chapter I to which the present regulations apply and to including cargo ships of 300 gross tonnage and upwards engaged on international voyages.

Clearer definition of the application, in

accordance with MSC.1/Circ.1500,

paragraph 4.2.2

1 Unless expressly provided otherwise, this chapter applies to all ships as provided in to which chapter I including applies and, in addition cargo ships of 300 gross tonnage and upwards engaged on international voyages.

(Editorial suggestion) #1






2 This chapter does not apply to ships to which the present regulations would otherwise apply while such ships are being navigated within the Great Lakes of North America and their connecting and tributary water as far east as the lower exit of the St. Lambert Lock at Montreal in the Province of Quebec, Canada.1

3 No provision in this chapter shall prevent the use by any ship, survival craft or person in distress, of any means at their disposal to attract attention, make known their position and obtain help.

Regulation 2

Terms and definitions

1 For the purpose of this chapter, the following terms shall have the meanings defined below:

.1 Bridge-to-bridge communications means safety communications between ships from the position from which the ships are normally navigated.

.1 Bridge-to-bridge radiocommunications means safety telecommunications between ships from the position from which the ships are normally navigated, conducted by radio.

Harmonizing RR and SOLAS - RR

defines radiocommunication (RR 1.6),

and telecommunication (RR 1.3) but RR

does not define communication #4

.2 Continuous watch means that the radio watch concerned shall not be interrupted other than for brief intervals when the ship's receiving capability is impaired or blocked by its own communications or when the facilities are under periodical maintenance or checks.

1 Such ships are subject to special requirements relative to radio for safety purposes, as contained in the relevant agreement between Canada and the

United States of America.






.3 Digital selective calling (DSC) means a technique using digital codes which enables a radio station to establish contact with, and transfer information to, another station or group of stations, and complying with the relevant recommendations of the International Radio Consultative Committee (CCIR) Telecommunication Union Radiocommunication Sector (ITU-R). 2

Update to reference

.4 Direct-printing telegraphy means automated telegraphy techniques which comply with the relevant recommendations of the International Radio Consultative Committee (CCIR) Telecommunication Union Radiocommunication Sector (ITU-R). 2

Update to reference

.4bis Enhanced Group Call (EGC) means a system capable of sending coordinated broadcast Maritime Safety Information, including distress relays, in text format to a shipboard EGC receiver from the satellite service provider supporting the ship earth station carried on board.

New definition to support regulation 7.5

.4bis Enhanced Group Call (EGC) means a system capable of sending coordinated broadcasts of Maritime Safety Information, including distress relays, in text format to a shipboard EGC receiver from the recognized mobile-satellite service provider supporting the ship earth station carried on board.

(Editorial suggestions)

Note that “mobile-satellite service” (with

a hyphen) is used in the Radio

Regulations.

2 The name of the Committee was changed to "ITU Radiocommunication Sector" (ITU-R) due to Article 1 of the International Telecommunication Constitution,

Geneva 1992.






.4bis Enhanced Group Call (EGC) means a system capable of sending messages within a specified area coordinated broadcast Maritime Safety Information, including distress relays, in text format to a shipboard EGC receiver from the satellite service provider supporting the ship earth station carried on board.

Definition in line with present

Res.1001(25) 4.9.4 to specify the

broadcast in a specified area and

MSC.1- Circ.1364 revised SafetyNet

Manual for a generic definition (EGC

can include any type of messages such

as MSI, distress relays, SAR

information, security related information

or any other information broadcasted to

ships). EGC is a broadcasting method

within a specified area. The

coordination is made for MSI not for

SAR information.

.5 General radio communications means operational communications and public correspondence traffic, other than distress, urgency and safety messages, conducted by radio.

This aligns the definition with the ITU

Radio Regulations

.5 General radiocommunications means operational telecommunications, other than distress conducted by radio

Harmonizing RR and SOLAS #4

6 Inmarsat 3 means the Organization established by the Convention on the International

Maritime Satellite Organization adopted on 3 September 1976.

No longer needed as there is no

reference to "Inmarsat"

6 Global Maritime Distress and Safety System (GMDSS) means the global radiocommunications service based upon automated systems, both satellite and terrestrial, to provide distress alerting, promulgation of maritime safety information and general radiocommunications for mariners.

Proposed definition of GMDSS in order

to clarify types of functional

requirements in SOLAS IV/4 #3

3 The name of the Organization was changed to "International Mobile-Satellite Organization" (Inmarsat) by virtue of amendments to its Convention and

Operating agreement adopted by 10th (extraordinary) Assembly (5-9 December 1994).






.7 International NAVTEX service means the coordinated broadcast and automatic

reception on 518 kHz of maritime safety information by means of narrow-band direct-

printing telegraphy using the English language. 4

.8 Locating means the finding of ships, aircraft, units survival craft or persons in distress.

Update to terminology

.9 Maritime Ssafety Iinformation (MSI)5 means navigational and meteorological warnings, meteorological forecasts and other urgent safety related messages broadcast to ships.

Alignment with the Joint IMO/IHO/WMO

Manual on Maritime Safety Information

(MSI) published by the Organization

.10 Polar orbiting sSatellite service on 406 MHz means a service which is based on polar orbiting satellites a satellite system designed to detect distress beacons transmitting in the frequency band from 406.0 to 406.1 MHz. operating in the 406 MHz band which receive and relay distress alerts from satellite EPIRBs and which provides their position.

Update because the Cospas-Sarsat

system now uses satellites in other

orbits than polar

.11 Radio Regulations means the Radio Regulations annexed to, or regarded as being annexed to, the most recent International Telecommunication Convention complementing the Constitution and the Convention of the International Telecommunication Union which is in force at any time.

Update to ITU definition

11bis Recognized mobile-satellite service means the communication service provided by a satellite system recognized by the Organization. 6

New definition

11bis Recognized mobile-satellite service means the communication service provided by a satellite system recognized by the Organization, for use in the GMDSS. 6

Consider additional phrase proposed in

MSC 98/11/3 (UK).

4 Refer to the NAVTEX Manual approved by the Organization. 5 Refer to the Joint IMO/IHO/WMO Manual on Maritime Safety Information (MSI) 6 Refer to resolution A.1001(25) concerning criteria for the provision of mobile-satellite communication systems in the global maritime distress and safety

system (GMDSS).






11ter Other communications means any telecommunication other than distress, urgency, safety, general or security related communications.

New definition

11ter Other radiocommunications means any telecommunication, including public correspondence traffic, #5 other than distress, urgency, safety, general or security related communications.

Suggest “other radiocommunications”

and not “other communications”, this

latest expression is used in RR A.53. #4

And to precise that these

telecommunications are conducted by

radio and may use public

correspondence.

12 Sea area A1 means an area within the radiotelephone coverage of at least one VHF coast station in which continuous DSC alerting is available, as may be defined by a Contracting Government. 7

13 Sea area A2 means an area, excluding sea area A1, within the radiotelephone coverage of at least one MF coast station in which continuous DSC alerting is available, as may be defined by a Contracting Government. 7

14 Sea area A3 means an area, excluding sea areas A1 and A2, within the coverage of

an Inmarsat geostationary satellite a recognized mobile-satellite communication service

supported by the ship earth station carried on board in which continuous alerting is

available.

Revised definition

7 Refer to resolution A.801(19) concerning the provision of radio services for the global maritime distress and safety system, (GMDSS).






14 Sea area A3 means an area, excluding sea areas A1 and A2, within the coverage of

a recognized mobile-satellite communication service supported by the ship earth station

on board, in which continuous alerting is available.

In the preceding proposal, there is a

potential additional word which

introduces “recognized mobile-satellite

communication service”. This specific

form of the reference to satellite service

is not defined elsewhere in regulation 2.

There also needs to be an additional

comma after “on board” otherwise it

implies that it is the SES on board in

which continuous alerting needs to be

available. #2

15 Sea area A4 means an area outside of sea areas A1, A2 and A3. Revised definition

15 bis Security related communications means communications associated with the

update of security levels, security incidents or threat thereof and security-related

information prior to the entry of a ship into a port.

New definition

15 bis Security related radiocommunications means telecommunications, including

public correspondence traffic, associated with the update of security levels, security

incidents or threat thereof and security-related information prior to the entry of a ship into

a port, conducted by radio.

There is no direction in SOLAS XI-2/7 &

ISPS Code b/4.13 on how security-

related information can be performed.

MSC/Circ.1130 mentions only that

security-related information prior to the

entry of a ship may be submitted in an

electronic format… this can include the

use of Public Correspondence (e-mail).

#4






.16 Global Maritime Distress and Safety System (GMDSS) identities means maritime mobile services identity (MMSI), the ship's call sign, recognized mobile satellite service identities and serial number identity which may be transmitted by the ship's equipment and used to identify the ship.

#2

.16 Global Maritime Distress and Safety System (GMDSS) identities means maritime mobile services identityies (MMSI), the ship's call sign, recognized mobile-satellite service identities and serial number identity which may be transmitted by the ship's equipment and used to identify the ship.

.17 Recognized mobile-satellite service means the communication service provided by a satellite system recognized by the Organization, for use in the GMDSS.

New definition approved by MSC 98

from MSC 98/11/3 (UK).

.17 Recognized mobile-satellite service means the communication service provided by a satellite system recognized by the Organization, for use in the GMDSS.

See same definition in 11 bis

2 All other terms and abbreviations which are used in this chapter and which are defined in the Radio Regulations and in the International Convention on Maritime Search and Rescue (SAR), 1979, as may be amended, shall have the meanings as defined in those Regulations and the SAR Convention.






Regulation 3

Exemptions

1 The Contracting Governments consider it highly desirable not to deviate from the requirements of this chapter; nevertheless the Administration may grant partial or conditional exemptions to individual ships from the requirements of regulations 7 to 11 provided: .1 such ships comply with the functional requirements of regulation 4; and .2 the Administration has taken into account the effect such exemptions may have upon the general efficiency of the service for the safety of all ships.

.2 the Administration has considered taken into account the effect such exemptions may have upon the general efficiency of the service for the safety of all ships.


2 An exemption may be granted under paragraph 1 only: .1 if the conditions affecting safety are such as to render the full application of regulations 7 to 11 unreasonable or unnecessary;

.1 if the conditions affecting safety are such as to render the full application of regulations 7 to 11 unreasonable or unnecessary;


.2 in exceptional circumstances, for a single voyage outside the sea area or sea areas for which the ship is equipped.

.2 in exceptional circumstances, for a single voyage outside the sea area(s) or sea areas for which the ship is equipped.







3 Each Administration shall submit to the Organization, as soon as possible after the

first of January in each year, a report showing all exemptions granted under paragraphs

1 and 2 during the previous calendar year and giving the reasons for granting such

exemptions.

Regulation 4

Functional requirements

1 Every ship, while at sea, shall be capable of: .1 performing the global maritime distress and safety system (GMDSS) functions as follows: 8

.1 except as provided in regulations 8.1.1 and 10.1.4.3, of transmitting ship-to-

shore distress alerts by at least two separate and independent means, each

using a different radiocommunication service;

See proposed 2.1.6 for GMDSS

definition #3

Redundant references

.2 of receiving shore-to-ship distress alerts relays; Update to terminology

.3 of transmitting and receiving ship-to-ship distress alerts;

.4 of transmitting and receiving search and rescue coordinating communications;

.5 of transmitting and receiving on-scene communications;

.6 of transmitting and, as required by regulation V/19.2.3.2, receiving signals for

locating; 9

The reference is now obsolete

8 It should be noted that ships performing GMDSS functions should use the Guidance for avoidance of false distress alerts adopted by the Organization by

resolution A.814(19).






.7 of transmitting and receiving 10 maritime safety related information; Correction to align the terminology with the definition of MSI given in regulation 2

.7 of transmitting and receiving 10 maritime safety related information; General radiocommunications includes safety related information as defined in 2.1.5 #5

.7bis receiving Maritime Safety Information (MSI); Noting that MSI is a shore based

service

.7 receiving Maritime Safety Information (MSI), and .7bis transmitting and receiving safety related information;

Support merging 4.1.1.7 and 4.1.1.7bis

on the basis that this removes a

potential contradiction. #5

.8 of transmitting and receiving general radio communications to and from shore-based radio systems or networks subject to regulation 15.8; and

To align with the definition of general communications given in regulation 2

.8 transmitting and receiving general radiocommunications; and To align with the new proposed definition of general radiocommunications given in regulation 2.1.5 #4

. 9 of transmitting and receiving bridge-to-bridge communications.

.2 transmitting and receiving security-related communications, in accordance with the

requirements of the International Ship and Port Facility Security Code; and

This is a requirement of SOLAS XI-2

.2 transmitting and receiving security-related security related radiocommunications, in

accordance with the requirements of required by the International Ship and Port Facility

Security Code; and


(“security related” not hyphenated elsewhere) #2

9 Refer is to resolution A.614(15) concerning carriage of radar operating in the frequency band 9300-9500 MHz. 10 It should be noted that ships may have a need for reception of certain maritime safety information while in port






.2 transmitting and receiving security-related communications, in accordance with the

requirements of the International Ship and Port Facility Security Code; and

What is a radio installation capable of sending and receiving security communications that is not SSAS or a radio installation fitted for compliance with the requirements of chapter IV regulations 7, 8, 9, 10 or 11? What is the particular capability that makes a specific installation a new carriage requirement under Chapter IV necessary and different from both the existing requirements of Chapter IV and those in XI-2/6? Why is there a need to effectively repeat the requirement? If Chapter IV is referring to SSAS, then why is this not stated? From our perspective, none of this is clear, even having read the Review of the GMDSS. We strongly urge that the functional requirement in clause 4.2 is deleted (taking into account the conclusion of the High level Review of the GMDSS (NCSR 4/29, Annex 11, paragraph 5)) and the carriage requirement in 7.7 is carefully reconsidered to ensure that It is absolutely clear what the requirement is and how it might differ from the very similar requirements already in SOLAS regulation XI-2/6. #5






.3 transmitting and receiving other communications to and from shore-based systems or

networks.

This replaces the requirement to transmit and receive public correspondence previously required under general communications.

.3 transmitting and receiving other radiocommunications to and from shore-based

systems or networks.

See comments at 2.1.1 #4

.3 transmitting and receiving other communications to and from shore-based systems or

networks.

With particular reference to functional and carriage requirements relating to “Other communications”, We are concerned that this brings non-operational communications, including communications not otherwise required by SOLAS into the Chapter. The definition of “other communications” is too broad to be able to be considered as helping to clearly define the communications equipment that is required – it could for example include everything from M2M communications relating to condition based monitoring to crew and passenger internet access. Moreover, what is the particular capability that makes a specific installation a new carriage requirement under Chapter IV necessary? We strongly urge that the functional requirement in clause 4.3 and the carriage requirement in 7.8 are re-considered and deleted. #5






Regulation 4-1

GMDSS satellite providers

The Maritime Safety Committee shall determine the criteria, procedures and

arrangements for the evaluation, recognition, review and oversight of the provision of

mobile satellite communication services in the global maritime distress and safety

system (GMDSS) pursuant to the provisions of this chapter.

See new proposed SOLAS IV/2.1.6 for

the definition of GMDSS #3

The Maritime Safety Committee shall determine the criteria, procedures and

arrangements for the evaluation, recognition, review and oversight of the provision of

mobile-satellite communication services in the global maritime distress and safety

system (GMDSS) pursuant to the provisions of this chapter.

“mobile-satellite service” is used in the

Radio Regulations.






PART B

Undertakings by Contracting Governments 11

Regulation 5 Provision of radiocommunication services 1 Each Contracting Government undertakes to make available, as it deems practical and necessary either individually or in co-operation with other Contracting Governments, appropriate shore-based facilities for space and terrestrial radiocommunication services having due regard to the recommendations of the Organization. 12 These services are:

.1 a radiocommunication mobile-satellite service utilizing geostationary satellites in the

Maritime Mobile-Satellite Service a recognized satellite system;

Aligning terminology

.1 a recognized mobile-satellite service utilizing a recognized satellite system; We have a definition of “recognized

mobile-satellite service”.

.2 a radiocommunication service utilizing polar orbiting satellites in the mobile-satellite

service operating on 406 MHz;

Aligning terminology

.3 the maritime mobile service in the bands between 156 MHz and 174 MHz;

.4 the maritime mobile service in the bands between 4000 kHz and 27 500 kHz; and

.5 the maritime mobile service in the bands between 415 kHz and 535 kHz 13 and between 1605 KHz and 4000 KHz.

11 1. Each Contracting Government is not required to provide all radiocommunication services. 2. The requirements should be specified for shore-based facilities to cover the various sea areas. 12 Refer to resolution A.801(19) concerning provision of radio services for the global maritime distress and safety system (GMDSS). 13 Refer to resolution A.617(15) concerning implementation of the NAVTEX system as a component of the World-Wide Navigational Warning Service.






2 Each Contracting Government undertakes to provide the Organization with pertinent information concerning the shore-based facilities in the maritime mobile service, mobile-satellite service and Maritime Mobile-Satellite Service, established for sea areas which it has designated off its coasts. 14

Regulation 5-1 Global maritime distress and safety system identities 1 This regulation applies to all ships on all voyages. 2 Each Contracting Government undertakes to ensure that suitable arrangements are made for registering global maritime distress and safety system (GMDSS) identities and for making information on these identities available to rescue coordination centres on a 24-hour basis. Where appropriate, international organizations maintaining a registry of these identities shall be notified by the Contracting Government of these assignments.

14 The Master Plan of shore-based facilities for the GMDSS based on information provided by Contracting Governments is circulated to all concerned by means of

GMDSS circulars.






PART C

Ship requirements

Regulation 6

Radio installations

1 Every ship shall be provided with radio installations capable of complying with the functional requirements prescribed by regulation 4 throughout its intended voyage and, unless exempted under regulation 3, complying with the requirements of regulation 7 and, as appropriate for the sea area or areas through which it will pass during its intended voyage, the requirements of either regulation 8, 9, 10 or 11. 2 Every radio installation shall:

.1 be so located that no harmful interference of mechanical, electrical or other origin affects its proper use, and so as to ensure electromagnetic compatibility and avoidance of harmful interaction with other equipment and systems;

.2 be so located as to ensure the greatest possible degree of safety and operational availability;

.3 be protected against harmful effects of water, extremes of temperature and other adverse environmental conditions;

.4 be provided with reliable, permanently arranged electrical lighting independent of the main and emergency sources of electrical power for the adequate illumination of the radio controls for operating the radio installation; and






.5 be clearly marked with the call sign, the ship station identity and other codes for the

operator with the codes as applicable for the use of the radio installation, such as ship's

name, call sign, the maritime mobile service identity (MMSI), mobile-satellite system

identities, or serial number identity.

Update to include codes in addition to

call signs

.5 be clearly marked for the operator with the codes GMDSS identities as applicable for

the use of the radio installation, such as ship's name, call sign, the maritime mobile

service identity (MMSI), mobile-satellite system identities, or serial number identity.

See definition for GMDSS identities. #2

3 Control of the VHF radiotelephone channels, required for navigational safety, shall be immediately available on the navigating bridge convenient to the conning position and, where necessary, facilities should be available to permit radiocommunications from the wings of the navigating bridge. Portable VHF equipment may be used to meet the latter provision.

3 Control of the VHF radiotelephone channels, required for navigational safety, shall be immediately available on the navigating bridge convenient to the conning position from which the ship is normally navigated and, where necessary, facilities should be available to permit radiocommunications from the wings of the navigating bridge. Portable VHF equipment may be used to meet the latter provision.

“position from which the ship is normally

navigated” is used in reg.7

4 In passenger ships, a distress panel shall be installed at the conning position. This panel shall contain either one single button which, when pressed, initiates a distress alert using all radiocommunication installations required on board for that purpose or one button for each individual installation. The panel shall clearly and visually indicate whenever any button or buttons have been pressed. Means shall be provided to prevent inadvertent activation of the button or buttons. If the satellite EPIRB is used as the secondary means of distress alerting and is not remotely activated, it shall be acceptable to have an additional EPIRB installed in the wheelhouse near the conning position.

Remote activation of EPIRBs was a

feature of the Inmarsat E system but is

not widely available with 406 MHz

EPIRBs






4 In passenger ships, a distress panel shall be installed at the conning position. This panel shall contain either one single button which, when pressed, initiates a distress alert using all radiocommunication installations required on board for that purpose or one button for each individual installation. The panel shall clearly and visually indicate whenever any button or buttons have been pressed. Means shall be provided to prevent inadvertent activation of the button or buttons. If the satellite EPIRB is used as the secondary means of distress alerting and is not remotely activated, it shall be acceptable to have an additional EPIRB installed in the wheelhouse near the conning position.

Although not disagreeing with the

availability of remote operated 406MHz

beacons, if this regulation is drafted in

this way it may prevent future, remote

operated beacons being used on board.

Is this the intention?

Also at 8.1.2, 9.3.1, 10.4.1 and 11.3.1

#6

5 In passenger ships, information on the ship's position shall be continuously and automatically provided to all relevant radiocommunication equipment to be included in the initial distress alert when the button or buttons on the distress panel is pressed.

This requirement is now included in

regulation 18

6 In passenger ships, a distress alarm panel shall be installed at the conning position. The distress alarm panel shall provide visual and aural indication of any distress alert or alerts received on board and shall also indicate through which radiocommunication service the distress alerts have been received.

Regulation 7

Radio equipment: General

1 Every ship shall be provided with:






.1 a VHF radio installation capable of transmitting and receiving: .1.1 DSC on the frequency 156.525 MHz (channel 70). It shall be possible to initiate the transmission of distress alerts on channel 70 from the position from which the ship is normally navigated; 15 and .1.2 radiotelephony on the frequencies 156.300 MHz (channel 6), 156.650 MHz (channel 13) and 156.800 MHz (channel 16);

.2 a radio installation capable of maintaining a continuous DSC watch on VHF channel 70 which may be separate from, or combined with, that required by subparagraph .1.1; 16

.3 a search and rescue locating device capable of operating either in the 9 GHz band or on frequencies dedicated for AIS, which: .3.1 shall be so stowed that it can be easily utilized; and .3.2 may be one of those required by regulation III/6.2.2 for a survival craft subparagraph .10;

Consequential change arising from

moving SOLAS III requirements to

SOLAS IV

.4 a receiver capable of receiving International NAVTEX service broadcasts if the ship is engaged on voyages in any area in which an International NAVTEX service is provided. However, ships engaged exclusively on voyages in areas where other terrestrial communications for receiving MSI is provided and fitted with equipment capable of receiving such service, may be exempt from this requirement;

Addition of arrangements for alternative

methods to NAVTEX for receiving MSI

15 Certain ships may be exempted from this requirement (see regulation 9.4). 16 Certain ships may be exempted from this requirement (see regulation 9.4).






.5 a radio facility for reception of maritime safety information by the recognized mobile satellite service enhanced group calling system 17 if the ship is engaged on voyages in [any area of recognized mobile satellite service coverage] [sea area A1, or A2 or A3] but in which an international NAVTEX service is not provided. However, ships engaged exclusively on voyages in areas where an HF direct-printing telegraphy maritime safety information service is provided and fitted with equipment capable of receiving such service may be exempt from this requirement. 18

Alternative text approved by MSC 98 as

proposed in MSC 98/11/4(UK). Note

that MSC did not decide on the words in

square brackets, so that decision may

be taken at MSC 99 when the

amendments are expected to be

adopted. NCSR 5 may wish to make a

recommendation.

.5 a radio facility for reception of MSI maritime safety information by the recognized mobile-satellite service enhanced group calling system 17 if the ship is engaged on voyages in any area of recognized mobile satellite service coverage supported by the ship earth station installed on board but in which an international NAVTEX service is not provided. However, ships engaged exclusively on voyages in areas where an HF direct-printing telegraphy maritime safety information service or other means of receiving MSI is provided and fitted with equipment capable of receiving such service may be exempt from this requirement. 18

Revisions from Appendix 3, NCSR

3/17, Annex

17 Refer to resolution A.701(17) concerning carriage of Inmarsat enhanced group call SafetyNET receivers under the GMDSS. 18 Refer to the Recommendation on promulgation of maritime safety information adopted by the Organization by resolution A.705(17).






.6 subject to the provisions of regulation 8.3, a satellite emergency position-indicating radio beacon (satellite EPIRB) 19 which shall be: .6.1 capable of transmitting a distress alert through the polar orbiting satellite service operating in the on 406 MHz band; .6.2 installed in an easily accessible position; .6.3 ready to be manually released and capable of being carried by one person into a survival craft; .6.4 capable of floating free if the ship sinks and of being automatically activated when afloat; and .6.5 capable of being activated manually.

Regulation 8.3 (VHF EPIRB) has been

deleted

Alignment of terminology

.7 a radio installation capable of transmitting and receiving security-related

communications. This requirement may be fulfilled by the addition of this capability in the

equipment required by regulations 8, 9, 10 or 11 or with that provided for subparagraph

.8.

This is a new requirement resulting

from regulation 4

.7 a radio installation capable of transmitting and receiving #2 security-related security

related radiocommunications. This requirement may be fulfilled by the addition of this

capability in the equipment required by regulations 8, 9, 10 or 11 or with that provided

for subparagraph .8.

To be in line with new proposed

definition of “security related

radiocommunications” #4

19 Refer to resolution A.616(15) concerning search and rescue homing capability.






.8 a radio installation capable of transmitting and receiving other communications to and

from shore based systems or networks. This requirement may be fulfilled by the addition

of this capability in the equipment required by regulations 8, 9, 10 or 11 or with that

provided for subparagraph .7

This is a new requirement resulting

from regulation 4

.8 a radio installation capable of transmitting and receiving other radiocommunications to

and from shore based systems or networks. This requirement may be fulfilled by the

addition of this capability in the equipment required by regulations 8, 9, 10, 11 or with

that provided for in subparagraph 7.


.8 a radio installation capable of transmitting and receiving other communications to and

from shore based systems or networks. This requirement may be fulfilled by the

addition of this capability in the equipment required by regulations 8, 9, 10, or 11 or with

that provided for subparagraph .7.

See comment at 4.3 #5

.9 at least two two-way VHF radio-telephone apparatus on every cargo ship of 300 tons

gross tonnage and upwards but less than 500 gross tonnage. At least three two-way

VHF radiotelephone apparatus on every passenger ship and on every cargo ship of 500

gross tonnage and upwards. At least two two-way VHF radio-telephone apparatus shall

be provided on every cargo ship of 300 tons gross tonnage and upwards but less than

500 gross tonnage. The two-way VHF radiotelephone apparatus may be portable or

fitted in a survival craft.

Moved from regulation III/6.2.1.1






.10 at least one search and rescue locating device on every cargo ship of 300 gross

tonnage and upwards but less than 500 gross tonnage. At least one search and rescue

locating device on each side of every passenger ship and of every cargo ship of 500

tons gross tonnage and upwards. At least one search and rescue locating device shall

be carried on every cargo ship of 300 tons gross tonnage and upwards but less than

500 tons gross tonnage. The search and rescue locating devices shall be stowed in

such locations that they can be rapidly placed in any survival craft other than the liferaft

or liferafts required by regulation III/31.1.4. Alternatively one search and rescue locating

device shall be stowed in each survival craft other than those required by regulation

III/31.1.4. On ships carrying at least two search and rescue locating devices and

equipped with free-fall lifeboats one of the search and rescue locating devices shall be

stowed in a free-fall lifeboat and the other located in the immediate vicinity of the

navigating bridge so that it can be utilized on board and ready for transfer to any of the

other survival craft.

Moved from regulation III/6.2.2

2 Every passenger ship shall be provided with means for two-way on-scene

radiocommunications for search and rescue purposes using the aeronautical

frequencies 121.5 MHz and 123.1 MHz from the position from which the ship is normally

navigated. This two-way on-scene radiocommunication means may be portable.

Portable equipment is common industry

practice

Regulation 8

Radio equipment: Sea area A1

1 In addition to meeting the requirements of regulation 7, every ship engaged on voyages exclusively in sea area A1 shall be provided with a radio installation capable of initiating the transmission of ship-to-shore distress alerts from the position from which the ship is normally navigated, operating either:






.1 on VHF using DSC; this requirement may be fulfilled by the EPIRB prescribed by paragraph 3, either by installing the EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or

Paragraph 3 has been deleted

.2 through the polar orbiting satellite service on 406 MHz; this requirement may be fulfilled by the satellite EPIRB, required by regulation 7.1.6, either by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or




EPIRBs

.2 through the satellite service on 406 MHz by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or

See remote activation comment at 6.4

#6

.3 if the ship is engaged on voyages within coverage of MF coast stations equipped with DSC, on MF using DSC; or .4 on HF using DSC; or

.5 through a recognized mobile-satellite service; this requirement may be fulfilled by: 5.1 a ship earth station providing a recognized mobile satellite service; 20 or .5.2 the satellite EPIRB, required by regulation 7.1.6, either by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated.

The options in 5.1 and 5.2 are no longer

required because the Inmarsat E EPIRB

service has been withdrawn. The option of

using an EPIRB has already been given in

.2

20 This requirement can be met by Inmarsat ship earth stations capable of two-way communications such as Inmarsat-A, Inmarsat-B (resolution A.808(19)) or

Inmarsat-C (resolution A.807(19)) ship earth stations. Unless otherwise specified, this footnote applies to all requirements for an Inmarsat ship earth station prescribed by this chapter.






2 The VHF radio installation, required by regulation 7.1.1, shall also be capable of transmitting and receiving general radiocommunications using radiotelephony.

This is intended to make the

requirement more generic

2 The VHF radio installation, required by regulation 7.1.1, shall also be capable of transmitting and receiving general radiocommunications.


3 Ships engaged on voyages exclusively in sea area A1 may carry, in lieu of the satellite EPIRB required by regulation 7.1.6, an EPIRB which shall be: .1 capable of transmitting a distress alert using DSC on VHF channel 70 and providing for locating by means of a radar transponder operating in the 9 GHz band; .2 installed in an easily accessible position; .3 ready to be manually released and capable of being carried by one person into a survival craft; .4 capable of floating free if the ship sinks and being automatically activated when afloat; and .5 capable of being activated manually.

The VHF EPIRB option has never been

implemented

Regulation 9

Radio equipment: Sea areas A1 and A2

1 In addition to meeting the requirements of regulation 7, every ship engaged on voyages beyond sea area A1, but remaining within sea area A2, shall be provided with:






.1 an MF radio installation capable of maintaining a continuous DSC watch on the frequency 2187.5 kHz and transmitting and receiving, for distress and safety purposes, on the frequencies: .1.1 2187.5 kHz using DSC; and .1.2 2182 kHz using radiotelephony; and .2 a radio installation capable of maintaining a continuous DSC watch on the frequency 2187.5 kHz which may be separate from, or combined with, that required by subparagraph .1.1; and .3 means of initiating the transmission of ship-to-shore distress alerts by a radio service other than MF operating either: .3.1 through the polar orbiting satellite service on 406 MHz; this requirement may be fulfilled by the satellite EPIRB, required by regulation 7.1.6, either by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or .3.2 on HF using DSC; or

The "separate" option is not now the

current practice of equipment design




EPIRBs


#6

.3.3 through by a ship earth station providing a recognized mobile satellite service.

.3.3 through by a ship earth station providing a recognized mobile-satellite service.

Editorial #2

2 It shall be possible to initiate transmission of distress alerts by the radio installations specified in paragraphs 1.1 and 1.3 from the position from which the ship is normally navigated.






3 The ship shall, in addition, be capable of transmitting and receiving general radio communications using radiotelephony or direct-printing telegraphy by either:



3 The ship shall, in addition, be capable of transmitting and receiving general radiocommunications by either:


.1 a radio installation operating on working frequencies in the bands between 1605 kHz and 4000 kHz or between 4000 kHz and 27 500 kHz. This requirement may be fulfilled by the addition of this capability in the equipment required by paragraph 1.1; or

.2 a ship earth station providing a recognized mobile-satellite service.

4 The Administration may exempt ships constructed before 1 February 1997, which are engaged exclusively on voyages within sea area A2, from the requirements of regulations 7.1.1.1 and 7.1.2 provided such ships maintain, when practicable, a continuous listening watch on VHF channel 16. This watch shall be kept at the position from which the ship is normally navigated.

Deleted because of reference to older

ships and the continuous listening

watch on VHF channel 16 is now

required by regulation 12.3

4 The Administration may exempt ships constructed before 1 February 1997, engaged exclusively in voyages within sea area A2, from the requirements of regulations 7.1.1.1 and 7.1.2 provided such ships comply with regulation 12.3.1.

We question whether deletion of the

provision. Such ships are still be in

operation and therefore this provision

cannot simply be deleted because the

application of this chapter is to all ships.

#7






Regulation 10

Radio equipment: Sea areas A1, A2 and A3

1 In addition to meeting the requirements of regulation 7, every ship engaged on voyages beyond sea areas A1 and A2, but remaining within sea area A3, shall, if it does not comply with the requirements of paragraph 2, be provided with:

Paragraph 2 has been deleted

.1 a ship earth station providing a recognized mobile-satellite service and capable of:

.1.1 transmitting and receiving distress and safety communications using direct-printing telegraphy; .1.2 initiating and receiving distress priority calls;

.1.3 maintaining watch for shore-to-ship distress alerts, including those directed to specifically defined geographical areas;

.1.3 maintaining watch for shore-to-ship distress alert relays, including those directed to specifically defined geographical areas;

To agree with functional requirement #2






.1.4 transmitting and receiving general radiocommunications, using either radiotelephony or direct-printing telegraphy; and .2 an MF radio installation capable of maintaining a continuous DSC watch on the frequency 2187.5 kHz and transmitting and receiving, for distress and safety purposes, on the frequencies: .2.1 2187.5 kHz using DSC; and .2.2 2182 kHz using radiotelephony; and .3 a radio installation capable of maintaining a continuous DSC watch on the frequency 2187.5 kHz which may be separate from or combined with that required by subparagraph .2.1; and .4 means of initiating the transmission of ship-to-shore distress alerts by a radio service operating either: .4.1 through the polar orbiting satellite service on 406 MHz; this requirement may be fulfilled by the satellite EPIRB, required by regulation 7.1.6, either by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or .4.2 on HF using DSC; or



The "separate" option is not now the

current practice of equipment design




EPIRBs


#6

.4.3 through a recognized mobile-satellite service on an additional ship earth station;

2 In addition to meeting the requirements of regulation 7, every ship engaged on voyages beyond sea areas A1 and A2, but remaining within sea area A3, shall, if it does not comply with the requirements of paragraph 1, be provided with:

Paragraph 2 (the MF/HF option) has

been removed from regulation 10 and

moved to regulation 11






.1 an MF/HF radio installation capable of transmitting and receiving, for distress and safety purposes, on all distress and safety frequencies in the bands between 1605 kHz and 4000 kHz and between 4000 kHz and 27 500 kHz: .1.1 using DSC; .1.2 using radiotelephony; and .1.3 using direct-printing telegraphy; and .2 equipment capable of maintaining DSC watch on 2187.5 kHz, 8414.5 kHz and on at least one of the distress and safety DSC frequencies 4207.5 KHz, 6312 kHz, 12 577 kHz or 16 804.5 kHz; at any time, it shall be possible to select any of these DSC distress and safety frequencies. This equipment may be separate from, or combined with, the equipment required by subparagraph .1; and .3 means of initiating the transmission of ship-to-shore distress alerts by a radio communication service other than HF operating either: .3.1 through the polar orbiting satellite service on 406 MHz; this requirement may be fulfilled by the satellite EPIRB, required by regulation 7.1.6, either by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or .3.2 through the Inmarsat geostationary a recognized mobile satellite service by on a ship earth station; and .4 in addition, ships shall be capable of transmitting and receiving general radio communications using radiotelephony or direct-printing telegraphy by an MF/HF radio installation operating on working frequencies in the bands between 1605 kHz and 4000 kHz and between 4000 kHz and 27 500 kHz. This requirement may be fulfilled by the






addition of this capability in the equipment required by subparagraph .1

3 It shall be possible to initiate transmission of distress alerts by the radio installations specified in paragraphs 1.1, 1.2, 1.4, 2.1 and 2.3 from the position from which the ship is normally navigated.

4 The Administration may exempt ships constructed before 1 February 1997, and engaged exclusively on voyages within sea areas A2 and A3, from the requirements of regulations 7.1.1.1 and 7.1.2 provided such ships maintain, when practicable, a continuous listening watch on VHF channel 16. This watch shall be kept at the position from which the ship is normally navigated.











#7

Regulation 11

Radio equipment: Sea areas A1, A2, A3 and A4

1 In addition to meeting the requirements of regulation 7, ships engaged on voyages in all sea areas shall be provided with the radio installations and equipment required by regulation 10.2, except that the equipment required by regulation 10.2.3.2 shall not be accepted as an alternative to that required by regulation 10.2.3.1, which shall always be provided. In addition, ships engaged on voyages in all sea areas shall comply with the requirements of regulation 10.3.

This is deleted and replaced with the

text of paragraph 10.2 2 (the MF/HF

option)






1 In addition to meeting the requirements of regulation 7, every ship engaged on voyages beyond sea areas A1 and A2 and A3, but remaining within sea area A4, shall, if it does not comply with the requirements of paragraph 1, be provided with: .1 an MF/HF radio installation capable of transmitting and receiving, for distress and safety purposes, on all distress and safety frequencies in the bands between 1605 kHz and 4000 kHz and between 4000 kHz and 27 500 kHz: .1.1 using DSC; and .1.2 using radiotelephony; and .1.3 using direct-printing telegraphy; and .2 equipment capable of maintaining DSC watch on 2187.5 kHz, 8414.5 kHz and on at least one of the distress and safety DSC frequencies 4207.5 KHz, 6312 kHz, 12 577 kHz or 16 804.5 kHz; at any time, it shall be possible to select any of these DSC distress and safety frequencies. This equipment may be separate from, or combined with, the equipment required by subparagraph .1; and .3 means of initiating the transmission of ship-to-shore distress alerts by a radio communication service other than HF operating either: .3.1 through the polar orbiting satellite service on 406 MHz; this requirement may be fulfilled by the satellite EPIRB, required by regulation 7.1.6, either by installing the satellite EPIRB close to, or by remote activation from, the position from which the ship is normally navigated; or

Redundant reference

The use of direct printing telegraphy in

distress messages is reported by

Administrations to be negligible. It is

unlikely today that any crew in distress

would initiate a follow-up

communication via direct printing

telegraphy




EPIRBs






.3.2 through the a recognized mobile satellite service on a ship earth station; and .4 in addition, ships shall be capable of transmitting and receiving general radio communications using radiotelephony or direct-printing telegraphy by an MF/HF radio installation operating on working frequencies in the bands between 1605 kHz and 4000 kHz and between 4000 kHz and 27 500 kHz. This requirement may be fulfilled by the addition of this capability in the equipment required by subparagraph .1


#6

3 It shall be possible to initiate transmission of distress alerts by the radio installations specified in paragraphs 1.1, and 1.3 1.2, 1.4, 2.1 and 2.3 from the position from which the ship is normally navigated.

2 The Administration may exempt ships constructed before 1 February 1997, and engaged exclusively on voyages within sea areas A2, A3 and A4, from the requirements of regulations 7.1.1 and 7.1.2 provided such ships maintain, when practicable, a continuous listening watch on VHF channel 16. This watch shall be kept at the position from which the ship is normally navigated.











#7






Regulation 12

Watches

1 Every ship, while at sea, shall maintain a continuous radio watch: .1 on VHF DSC channel 70, if the ship, in accordance with the requirements of regulation 7.1.2, is fitted with a VHF radio installation; .2 on the distress and safety DSC frequency 2,187.5 kHz, if the ship, in accordance with the requirements of regulation 9.1.2 or 10.1.3, is fitted with an MF radio installation; .3 on the distress and safety DSC frequencies 2,187.5 kHz and 8,414.5 kHz and also on at least one of the distress and safety DSC frequencies 4,207.5 kHz, 6,312 kHz, 12,577 kHz or 16,804.5 kHz, appropriate to the time of day and the geographical position of the ship, if the ship, in accordance with the requirements of regulation 10.2.2 or 11.1, is fitted with an MF/HF radio installation. This watch may be kept by means of a scanning receiver;

Update to terminology

.4 for satellite shore-to-ship distress alerts relays, if the ship, in accordance with the requirements of regulation 10.1.1, is fitted with a ship earth station providing a recognized maritime mobile service.

.4 for satellite shore-to-ship distress alert relays, if the ship, in accordance with the requirements of regulation 10.1.1, is fitted with a ship earth station providing a recognized maritime mobile-satellite service.

For consistent terminology #2

2 Every ship, while at sea, shall maintain a radio watch for broadcasts of maritime safety information on the appropriate frequency or frequencies on which such information is broadcast for the area in which the ship is navigating.






3 Until 1 February 1999 or until such other date as may be determined by the Maritime Safety Committee, 21Every ship while at sea shall maintain, when practicable, a continuous listening watch on VHF channel 16. This watch which shall be kept at the position from which the ship is normally navigated on; .1 VHF channel 16, and;

The Maritime Safety Committee

decided (resolution MSC.131(75) that

all GMDSS ships, while at sea, shall

continue to maintain, when practicable,

continuous listening watch on VHF

channel 16.

.2 appropriate frequency or frequencies for general communications for the area in which the ship is navigating.

The addition adds a requirement for

VTS etc.

.2 appropriate frequency or frequencies for general radiocommunications for the area in which the ship is navigating.

To align with the new proposed

definition of general

radiocommunications given in

regulation 2.1.5 #4

Regulation 13

Sources of energy

1 There shall be available at all times, while the ship is at sea, a supply of electrical energy sufficient to operate the radio installations and to charge any batteries used as part of a reserve source or sources of energy for the radio installations.

21 The maritime Safety Committee decided (resolution MSC.131(75) and all GMDSS ships, while at sea, shall continue to maintain, when practicable,

continuous listening watch on VHF channel 16.






2 A reserve source or sources of energy shall be provided on every ship, to supply radio installations, for the purpose of conducting distress and safety radio communications, in the event of failure of the ship's main and emergency sources of electrical power. The reserve source or sources of energy shall be capable of simultaneously operating the VHF radio installation required by regulation 7.1.1 and, as appropriate for the sea area or sea areas for which the ship is equipped, either the MF radio installation required by regulation 9.1.1, the MF/HF radio installation required by regulation 10.2.1 or 11.1, or the ship earth station required by regulation 10.1.1 and any of the additional loads mentioned in paragraphs 4, 5 and 8 for a period of at least:

.1 1 h on ships provided with an emergency source of electrical power, if such source of power complies fully with all relevant provisions of regulation II-1/42 or 43, including the supply of such power to the radio installations; and .2 6 h on ships not provided with an emergency source of electrical power complying fully with all relevant provisions of regulation II-1/42 or 43, including the supply of such power to the radio installations 22.

3 The reserve source or sources of energy shall be independent of the propelling power of the ship and the ship's electrical system.

22 For guidance the following formula is recommended for determining the electrical load to be supplied by the reserve source of energy for each radio

installation required for distress conditions: 1/2 of the current consumption necessary for transmission + the current consumption necessary for reception + the current consumption of any additional loads.






4 Where, in addition to the VHF radio installation, two or more of the other radio installations, referred to in paragraph 2, can be connected to the reserve source or sources of energy, they shall be capable of simultaneously supplying, for the period specified, as appropriate, in paragraph 2.1 or 2.2, the VHF radio installation and: .1 all other radio installations which can be connected to the reserve source or sources of energy at the same time; or .2 whichever of the other radio installations will consume the most power, if only one of the other radio installations can be connected to the reserve source or sources of energy at the same time as the VHF radio installation.

5 The reserve source or sources of energy may be used to supply the electrical lighting required by regulation 6.2.4.

6 Where a reserve source of energy consists of a rechargeable accumulator battery or batteries: .1 a means of automatically charging such batteries shall be provided which shall be capable of recharging them to minimum capacity requirements within 10 h; and .2 the capacity of the battery or batteries shall be checked, using an appropriate method,23 at intervals not exceeding 12 months, when the ship is not at sea.

23 One method of checking the capacity of an accumulator battery is to fully discharge and recharge the battery, using normal operating current and period

(e.g. 10 h). Assessment of the charge condition can be made at any time, but it should be done without significant discharge of the battery when the ship is at sea.






7 The siting and installation of accumulator batteries which provide a reserve energy shall be such as to ensure: .1 the highest degree of service; .2 a reasonable lifetime; .3 reasonable safety; .4 that battery temperatures remain within the manufacturer's specifications whether under charge or idle; and .5 that when fully charged, the batteries will provide at least the minimum required hours of operation under all weather conditions.

8 If an uninterrupted input of information from the ship's navigational or other equipment to a radio installation required by this chapter, including the navigation receiver referred to regulation 18, is needed to ensure its proper performance, means shall be provided to ensure the continuous supply of such information in the event of failure of the ship's main or emergency source of electrical power






Regulation 14

Performance standards

1 All equipment to which this chapter applies shall be of a type approved by the Administration. Such equipment shall conform to appropriate performance standards not inferior to those adopted by the Organization.24 Regulation 15

Maintenance requirements

1 Equipment shall be so designed that the main units can be replaced readily, without elaborate recalibration or readjustment.

24 Refer to the following resolutions adopted by the Assembly of the Organization:

.1 Resolution A.523(13) MSC.148(77): Performance standards for narrow-band direct-printing telegraph equipment for the reception of navigational and meteorological warnings and urgent information to ships (NAVTEX) (valid for equipment installed on or after 1 July 2005).

.2 Resolution A.694(17): General requirements for shipborne radio equipment forming part of the global maritime distress and safety system (GMDSS) and for electronic navigational aids.

.3 Resolution A.808(19): Performance standards for ship earth stations capable of two-way communications and resolution A.570(14): Type approval of ship earth stations.

.4 Resolution A.803(19): Performance standards for shipborne VHF radio installations capable of voice communication and digital selective calling as amended, and resolution MSC.68(68), annex 1 (valid for equipment installed on or after 1 January 2000).

.5 Resolution A.804(19): Performance standards for shipborne MF radio installations capable of voice communication and digital selective calling as amended, and resolution MSC.68(68), annex 2 (valid for equipment installed on or after 1 January 2000).

.6 Resolution A.806(19): Performance standards for shipborne MF/HF radio installations capable of voice communication, narrow-band direct-printing and digital selective calling as amended, and resolution MSC.68(68), annex 3 (valid for equipment installed on or after 1 January 2000).

.7 Resolution A.810(19): Performance standards for float-free satellite emergency position-indicating radio beacons (EPIRBs) operating on 406 MHz (see also Assembly resolution A.696(17): Type approval of satellite emergency position-indicating radio beacons (EPIRBs) operating in the Cospas-Sarsat system).

.8 Resolution A.802(19): Performance standards for survival craft radar transponders for use in search and rescue operations.

.9 Resolution MSC.246(83): Performance standards for survival craft AIS search and rescue transmitters (AIS-SART) for use in search and rescue operations.

.9 Resolution A.612(15): Performance standards for float-free VHF emergency position-indicating radio beacons.






2 Where applicable, equipment shall be so constructed and installed that it is readily accessible for inspection and on-board maintenance purposes.

3 Adequate information shall be provided to enable the equipment to be properly operated and maintained, taking into account the recommendations of the Organization. 25

4 Adequate tools and spares shall be provided to enable the equipment to be maintained.

5 The Administration shall ensure that radio equipment required by this chapter is maintained to provide the availability of the functional requirements specified in regulation 4 and to meet the recommended performance standards of such equipment.

.10 Resolution A.807(19): Performance standards for Inmarsat-C ship earth stations capable of transmitting and receiving direct-printing

communications as amended, and resolution MSC.68(68), annex 4 (valid for equipment installed on or after 1 January 2000) and resolution A.570(14): Type approval of ship earth stations.

.11 Resolution A.664(16) MSC.306(87): Performance standards for enhanced group call (EGC) equipment. .12 Resolution A.821(19): Performance standards for float-free satellite emergency position-indicating radio beacons operating through the

geostationary INMARSAT satellite system on 1.6 GHz. .13 Resolution A.662(16): Performance standards for float-free release and activation arrangements for emergency radio equipment. .14 Resolution A.699(17): System performance standard for the promulgation and co-ordination of maritime safety information using high-frequency

narrow-band direct-printing. .15 Resolution A.700(17): Performance standards for narrow-band direct-printing telegraph equipment for the reception of navigational and

meteorological warnings and urgent information to ships (MSI) by HF. .16 Resolution A.811(19): Performance standards for a shipborne integrated radiocommunication system (IRCS) when used in the GMDSS. .17 Resolution MSC.80(70), annex 1: Performance standards for on-scene (aeronautical) two-way portable VHF radiotelephone apparatus. .18 Resolution XXX MSC Performance standards for data structure and presentation of MSI information.

25 Refer to the Recommendation on general requirements for shipborne radio equipment forming part of the global maritime distress and safety system and for electronic navigational aids, adopted by the Organization by resolution A.694(17), and to resolution A.813(19) on general requirements for electromagnetic compatibility (EMC) for all electrical and electronic ship's equipment and to MSC/Circ.862: Clarifications of certain requirements in IMO performance standards for GMDSS equipment.






6 On ships engaged on voyages in sea areas A1 and or A2, the availability shall be ensured by using such methods as duplication of equipment, shore-based maintenance or at-sea electronic maintenance capability, or a combination of these, as may be approved by the Administration.

Correction

7 On ships engaged on voyages in sea areas A3 and or A4, the availability shall be ensured by using a combination of at least two methods such as duplication of equipment, shore-based maintenance or at-sea electronic maintenance capability, as may be approved by the Administration, taking into account the recommendations of the Organization 26.

Correction

8 While all reasonable steps shall be taken to maintain the equipment in efficient working order to ensure compliance with all the functional requirements specified in regulation 4, malfunction of the equipment for providing the general radio other communications required by regulation 4.83 shall not be considered as making a ship unseaworthy or as a reason for delaying the ship in ports where repair facilities are not readily available, provided the ship is capable of performing all distress and safety functions.

Consequential change resulting from

new regulation 4

8 While all reasonable steps shall be taken to maintain the equipment in efficient working order to ensure compliance with all the functional requirements specified in regulation 4, malfunction of the equipment for providing the general radio other radiocommunications required by regulation 4.83 shall not be considered as making a ship unseaworthy or as a reason for delaying the ship in ports where repair facilities are not readily available, provided the ship is capable of performing all distress and safety functions.

See comments at 2.1.1

26 Refer to resolution A.702(17) concerning radio maintenance guidelines for the global maritime distress and safety system related to sea areas A3 and A4.






9 Satellite EPIRBs shall be: .1 annually tested for all aspects of operational efficiency, with special emphasis on checking the emission on operational frequencies, coding and registration, at intervals as specified below: .1.1 on passenger ships, within 3 months before the expiry date of the Passenger Ship Safety Certificate; and .1.2 on cargo ships, within 3 months before the expiry date, or 3 months before or after the anniversary date, of the Cargo Ship Safety Radio Certificate. The test may be conducted on board the ship27 or at an approved testing station; and .2 subject to maintenance at intervals not exceeding five years, to be performed at an approved shore-based maintenance facility.

Regulation16

Radio personnel

1 Every ship shall carry personnel qualified for distress and safety radiocommunication purposes to the satisfaction of the Administration 28. The personnel shall be holders of certificates specified in the Radio Regulations as appropriate, any one of whom shall be designated to have primary responsibility for radiocommunications during distress incidents.

2 In passenger ships, at least one person qualified in accordance with paragraph 1

shall be assigned to perform only radiocommunication duties during distress incidents.

27 Guidelines on the annual testing of 406 MHz satellite EPIRBs are given in MSC/Circ.882. Guidance for avoidance of false distress alerts are given in

resolution A.814(19). 28 Refer to STCW Code, chapter IV, section B-IV/2.






Regulation 17

Radio records

A record shall be kept, to the satisfaction of the Administration and as required by the Radio Regulations, of all incidents connected with the radiocommunication service which appear to be of importance to safety of life at sea.

Regulation 18

Position-updating

All two-way communication equipment carried on board a ship to which this chapter applies which is capable of automatically including the ship's position in the distress alert shall be automatically provided with this information from an internal or external navigation receiver 29, if either is installed. If such a receiver is not installed, the ship's position and the time at which the position was determined shall be manually updated at intervals not exceeding 4 h, while the ship is underway, so that it is always ready for transmission by the equipment.

It is a requirement of SOLAS V/19.2.1.6

for the ship to carry the navigation

receiver so this text is no longer

required

__________

29 Requirements for automatic update of the ship's position are given in resolution MSC.68(68)

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